📄 Direct examination of Richard H. Fox — Wednesday, January 15, 1997
Address:
C:\DEPT103\CIVIL\1997\JAN\15\DIRECT-EXAMINATION-OF-RICHARD-.DOC
TRIAL
▲ Day 42 of 57

Direct examination of Richard H. Fox

Witness: Richard H. Fox
Examiner: Edward Medvene
Called by: Plaintiff • Date: Wednesday, January 15, 1997 • Utterances: 93
Plaintiff's expert Dr. Fox describes his laboratory experiments recreating the cutting of OJ Simpson's sock to demonstrate that blood particles could naturally fall onto the inner surface (wall 3) of a folded sock during the criminalist's cutting process. Using his own blood, he created a mockup replicating the bloodstain and photographed the resulting blood spheres and flakes that fell onto the clean fabric below. His central conclusion is that the presence of blood on wall 3 is consistent with contamination during cutting — not necessarily evidence of planting.
1 A:

Yes. And can I just add something to that statement?

2 Q:

Yes.

3 A:

Mr. Riegal was present for the cutting. He was not present for the entire operation.

4 Q:

Okay.

5 A:

And I did make another cutting, yes.

6 Q:

Okay. We'll put on the board what's marked 716, No. 17, and if you'd be good enough, Mr. Fox, have you a blow-up of this?

7 A:

Yes.

8 Q:

Would you mark that 2399?

9 A:

I have done so. (The instrument herein referred to as a photograph of page 7 of plaintiff's exhibit 716 was marked for identification as Plaintiffs' Exhibit No. 2399.)

10 Q:

Can you tell us what that is on the TV monitor?

11 A:

I located an area on the other sock, the sock that was not questioned, as far as the ankle stain, examined it thoroughly and found an area where there was no blood stain, and then I cut a swatch out of that sock. This photograph shows the sock is folded over so that when I cut out an inch long segment and then I opened it, it's a 2-inch long segment of clean fabric material from the pair of socks.

12 Q:

And it would measure about 2 by what?

13 A:

By a half.

14 Q:

Okay. Can you tell us what you did with that clean segment from the second sock that you cut out that was 2 by 1/2 an inch?

15 A:

I cut it into thirds. I took one-third and taped it down onto a piece of cardboard or paper -- something to hold it. I took another piece and laid it on some clean filter paper and I punctured my finger with a lancet. That is an implement that puts a neat little hole in your finger so you can get blood out of your own finger, drop by drop. And I got a drop on my finger and I touched it with the clean -- with the blood-free third of the sock that I had cut out. I then, as it absorbed into the fabric, did that a second time. I added another touch of a droplet from my finger to the swatch, thus creating a blood-rich stain on a small segment of the sock.

16 Q:

What did you then do?

17 A:

I allowed it to air dry. Then it was time to quit for the day. I packaged it and gave it to Mary Pearson (sic); that was on the 14th. And I arranged for her to come back on the 20th so I could finish my photography and examinations.

18 Q:

And what did she then take off?

19 A:

She took off everything. She took the socks, the wrappings, and all the cuttings, that is the third that had cut out, one now has a blood stain on it, she took that. She also took the cutting that I made around the halo area, the so-called halo area. Each of those items were put into a clean container and all packaged up and given to her and she removed them from the laboratory to be brought back at another date.

20 Q:

And was there another day when the items were brought back?

21 A:

Yes, on the 20th. She bought them back to the lab.

22 Q:

And who was present?

23 A:

Just myself.

24 Q:

And was she there?

25 A:

Yes.

26 Q:

And could you tell us then, what you did on the 20th?

27 A:

Yes. I held in forceps the little segment of sock that had the blood on it, which I refer to as mockup side 1, side 2. Over the clean piece of sock material that I had taped down so it wouldn't move around, which I would call mockup side 3, that is the side facing upwards, would be the equivalent of side 3, and I held the side 1, 2 over that, not touching it, but close, within say a half an inch or so -- I didn't measure it, and I cut a little piece out of the stain so that while I was cutting it, I could actually see -- actually see blood and material falling onto the mockup wall 3, that is, the clean piece of sock. Then I examined it microscopically and took photographs.

28 Q:

What did you observe?

29 A:

Well, I observed very similar results to the cutting of the halo, except that since I was dealing with more blood, there was more crust and more spherical -- and more rounded polished particles of blood, so that I had more to look at and to attempt to photograph. I'm sure -- I've been told already how difficult it has been -- how difficult to photograph what's been done prior. I did this and took some photomicrographs similar to what I did on the 14th with the halo cutting, and brought several into court today.

30 Q:

Now, had you, prior to doing the two experiments you told us about, seen the picture that Mr. MacDonell said was taken when he did his examination?

31 A:

Yes, I have.

32 MR. MEDVENE:

May I approach, Your Honor?

33 (Nods affirmative.)
34 Q:

(BY MR. MEDVENE) I show you what's been marked 1214 --

35 MR. FOSTER:

1241.

36 Q:

(BY MR. MEDVENE) Excuse me, 1241. I ask you if this is a blow-up of that picture?

37 A:

Yes, it is. (Counsel displayed Exhibit 1241.)

38 Q:

(BY MR. MEDVENE) You said that you took several pictures. Let me ask -- the first one to be put up on the TV screen is 716, No. 25. Do you have that in front, your blow-up?

39 A:

Yes.

40 Q:

Would you be good enough to mark the blow-up as 2400, sir?

41 A:

Okay, it's marked. (The instrument herein referred to as a photograph of mockup 3 was marked for identification as Plaintiffs' Exhibit No. 2400.)

42 Q:

Can you tell us what you see?

43 A:

Yes. What you're looking at is the mockup wall 3 with the blood that has fallen from my cutting of wall 1, 2. And there's quite a bit of blood here because it was a blood-rich segment that I had cut from; it had two drops of blood on it. And what is demonstrated, and what can be seen in the microscope, and I'll explain to you, are many flakes of blood and many spheres -- many rounded ball-like and spherical particles of blood, very similar in appearance to what Dr. Lee photographed for Herbert MacDonell at another time. Like snowflakes, no two are going to be identical, but the same -- following the same basic shape. We have blood that is dried. All blood was wet at one time, and that is rounded or spherical and has that polished appearance, as opposed to some of the other crusts which have a duller -- we call it the cornflake appearance.

44 Q:

Now, do you have in front of you what's marked 17, No. 32?

45 A:

Yes, I do.

46 Q:

Would you be good enough to put on the enlargement, 2401. And could you describe for the jury --

47 A:

Do you want to mark my blow-up?

48 Q:

Yes, sir. 2401. (The instrument herein referred to as a photograph of mockup 3 was marked for identification as Plaintiffs' Exhibit No. 2401.)

49 A:

Thank you.

50 Q:

And if you could tell me how it got there and what it is?

51 A:

Well, we're looking at the same thing right now, the mockup of side 3, the droppings, if you will. We have the reddish polished, we have the flakes, we have fibrils that have blood on it, and we have even what appears to be a fibril that's covered with blood that has fallen to the wall 3 area.

52 MR. MEDVENE:

And lastly, let's mark 716, that's picture No. 29.

53 A:

Do you want me to mark mine?

54 Q:

Would you mark yours. Do you have the blow-up in front of you?

55 A:

2402? Thank you. (The instrument herein referred to as photograph of page 10 of plaintiff's exhibit 716 was marked for identification as Plaintiffs' Exhibit No. 2402.)

56 MR. MEDVENE:

Mr. Foster, would you put that on the board, sir.

57 Q:

(BY MR. MEDVENE) Would you tell us and the ladies and gentlemen of the jury what you observed there and how it got there?

58 A:

Same mockup wall 3, cutting of the blood-rich segment. And this is really one of the fortuitous sections that I could see because it has numerous of the rounded, polished looking spherical blood stains.

59 RICHARD H. FOX:

I wonder if you can take that down a little bit. I think it may be -- okay. (Indicating to Elmo.)

60 RICHARD H. FOX:

Is that in focus all the way from where you are? Go the other way. (Indicating to Elmo.)

61 RICHARD H. FOX:

Little more. (Indicating to Elmo.)

62 MR. FOSTER:

That's it.

63 RICHARD H. FOX:

Okay. Thank you.

64 A:

I'm going to point out that there are numerous polished looking rounded droplets, as you will, blood particles, not the cornflake looking type, and this is a blow-up showing those. And if you look at the one that MacDonell had talked about, which interestingly enough is not totally rounded because it has more of an elliptical -- a length and width to it, you'll see that the same type of formations are seen on this photograph. In fact, when I look through the microscope, there are numerous such formations, some easier than others to get good photographs of. But this particular picture is very good and it has a number of the polished, rounded different sizes.

65 MR. MEDVENE:

Now, may I exhibit this to the jury, Your Honor?

66 THE COURT:

You may.

67 MR. MEDVENE:

This is No. 29 that's marked as 2402. (Jurors reviewed Exhibit 2402.)

68 Q:

(BY MR. MEDVENE) When you use the words "manipulate the balls," what do you mean by that word?

69 A:

I look under the microscope, I can see some of these spheric blood crusts; some look like they've fallen and are embedded between the fibers themselves, some appear to be on top of a thread or a fiber. The one thing that I can't tell when looking through the microscope -- and some appear to be loosely sitting there. But there are those that you cannot tell -- I cannot tell just by looking at it, since I can't see the underside, whether they would -- I know, of course, that they came from above. But if I look at them to see whether I would be able to tell whether they were bonded to wall 3, that is, had gone on wet, or had fallen, unless I get in with a forceps or a piece of wire, I use forceps and push at them a little bit. You don't want to break them up, but push at it a little bit. It's my opinion that you can't tell whether they are just lying on or even somewhat attached to the fibrils grabbing at the blood itself, unless you manipulate, unless you touch, unless you move it, unless you probe it in some way.

70 Q:

And you read Mr. MacDonell's testimony?

71 A:

Yes.

72 Q:

And he said he did not manipulate or touch the balls because of their smallness; is that correct?

73 A:

That's correct.

74 Q:

Now, do you have an opinion, sir, based upon your training and experience and the experiments that you did in this matter, as to whether or not the microscopic blood particles or flakes or spheres could have fallen to wall 3 of the sock when the blood-stain area was cut by the criminalist?

75 A:

My opinion --

76 MR. BAKER:

I'm going to object, Your Honor. That's irrelevant if it could have.

77 THE COURT:

Overruled.

78 A:

My answer to that question is that the blood could have fallen to wall 3 when it was cut, and I would be surprised if some blood didn't fall to wall 3 when it was cut.

KEY QUOTE
79 Q:

And the basis for your opinion, sir?

80 A:

Gravity. If wall 1 and 2 have blood, especially if there's enough blood to soak through wall 2, and it's sitting over wall 3, which when you cut it there are going to be flakes of blood dislodged just by the mechanical cutting, that has to go somewhere, and they're going to go down. If wall 3 is under it, it's going to fall on wall 3.

KEY QUOTE
81 Q:

Is your conclusion supported by any independent facts that you observed in the course of your experiment?

82 A:

Well, that's exactly what happened during my experiment; that when I cut wall 1 and 2 on the actual sock, blood fell to wall 3 when I did the mockup using the blood-rich sample; wall 3 mockup received blood when I cut it.

83 Q:

If one were to -- instead of performing the experiment you performed, if one were to have after the fact poured blood on side 1, what would you have expected to see, in your experience, with your background; what would you expect to see on wall 3?

84 A:

If the sock were lying in a position where wall 1 and 2 were covering wall 3, the liquid blood were put onto wall 1 sufficient to go through wall 1 and stain wall 2, then I would suspect that we should also get a stain on wall 3; the stain might be smaller in circumference than wall 1. Wall 2 would be somewhat smaller if the blood didn't go through in the peripheral areas. And wall 3 may also be smaller, but if you put a drop on that sock, as thin as it is, I would expect that there would be a stain on wall 3.

85 Q:

When you performed your experiment, did you find a stain on wall 3?

86 A:

I didn't do it in that manner, but when I put my blood on wall 1 --

87 MR. BAKER:

Move to strike as nonresponsive.

88 THE COURT:

Overruled.

89 A:

I put the blood on wall 1, on my mockup, and the blood went through to wall 2 and also went through to the filter paper, it was lying on -- leaving a red stain on the filter paper.

90 Q:

Thank you.

91 MR. MEDVENE:

I have nothing further.

92 THE COURT:

Cross-examine. CROSS-EXAMINATION BY MR. BAKER:

93 Q:

Dr. Fox, you know of Dr. Henry Lee's reputation as a criminalist, do you not?

Temperature

procedural

Key Quotes (4)

Richard H. Fox
My answer to that question is that the blood could have fallen to wall 3 when it was cut, and I would be surprised if some blood didn't fall to wall 3 when it was cut.
Direct rebuttal to the defense theory that blood on wall 3 of the sock was planted — Fox argues it would occur naturally during cutting.
Richard H. Fox
Gravity.
Fox's one-word summary of the basis for his scientific opinion — memorable and rhetorically effective for the jury.
Richard H. Fox
Like snowflakes, no two are going to be identical, but the same — following the same basic shape. We have blood that is dried. All blood was wet at one time, and that is rounded or spherical and has that polished appearance, as opposed to some of the other crusts which have a duller — we call it the cornflake appearance.
Explains the morphology of the blood particles he observed, mirroring what MacDonell found — undermining the defense's claim that the spheres were anomalous evidence of planting.
Richard H. Fox
I punctured my finger with a lancet. That is an implement that puts a neat little hole in your finger so you can get blood out of your own finger, drop by drop.
Fox walked the jury through his experimental methodology using his own blood, making the science accessible and demonstrating hands-on rigor.

Evidence (7)

Plaintiffs' 716
Multi-page exhibit containing photographs of the sock examination and mockup experiments
Used as source for blow-up photographs marked as 2399, 2400, 2401, 2402
Plaintiffs' 2399
Photograph of page 7 of Exhibit 716, showing the clean swatch cut from the second sock
Introduced and marked
Plaintiffs' 2400
Photograph of mockup wall 3 showing blood particles that fell during cutting experiment
Introduced and marked
Plaintiffs' 2401
Second photograph of mockup wall 3 showing blood droppings including fibrils with blood
Introduced and marked
Plaintiffs' 2402
Photograph of page 10 of Exhibit 716, showing numerous polished spherical blood particles on mockup wall 3
Introduced, marked, and exhibited to jury
Plaintiffs' 1241
Blow-up of a photograph taken by Dr. Henry Lee when he examined the sock for Herbert MacDonell
Displayed for comparison with Fox's experimental results
+ 1 more

Notable Exchanges (4)

MedveneRichard H. Fox
Fox explained that he used a lancet to draw his own blood and apply it to a sock swatch to create a mockup, then cut the bloodstained swatch over a clean piece of fabric to replicate what the criminalist did — observing blood fall to the clean surface below.
methodical
MedveneRichard H. Fox
Fox distinguished his methodology from MacDonell's: MacDonell declined to 'manipulate the balls' (probe the spheres with forceps) due to their smallness, while Fox argued you cannot determine whether particles are bonded or loosely resting without probing them.
strategic
BakerCourt
Baker objected that the question of whether blood 'could have' fallen was irrelevant, but the court overruled. Fox then gave his key conclusion including his memorable 'Gravity' response.
contentious
Richard H. FoxFoster (tech)
Fox directed the Elmo operator to adjust focus and positioning of Exhibit 2402 so the jury could see the spherical blood particles clearly.
routine

Light Moments (1)

Richard H. Fox
Fox directed the Elmo operator: 'Go the other way... Little more.' — a brief, mundane back-and-forth about getting the image in focus for the jury.

Credibility Attacks (1)

⚔ Herbert MacDonell
Methodology critique
Fox implicitly challenged MacDonell's conclusions by arguing that MacDonell's refusal to 'manipulate' (probe) the blood spheres meant he could not determine whether they were bonded to wall 3 or had fallen there — leaving his interpretation incomplete.

Witness Demeanor

(Indicating to Elmo.) — Fox directed the display technician multiple times to adjust the image on screen
Fox asked the attorney to confirm exhibit numbers and offered to mark his own blow-ups proactively, suggesting an organized, detail-oriented manner

Objections

2 objections (0 sustained, 2 overruled)
Proceeding 8815 • 93 utterances • Plaintiff witness
Civil Trial
Department 103
⚖️ Start
📂 JAN 15, 1997 📄 Direct examination of Richard
JAN 15, 1997 KRT DvH TD